ML20079F480

Supplemental Direct Testimony of G Jeffers & AR Rossi Re Contentions 25.C & 25.D

ML20079F480
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/16/1984
From:	Jeffers G, Rossi A SUFFOLK COUNTY, NY
To:
Shared Package
ML20079F461	List: ML20079F458 ML20079F480 ML20079F489 ML20079F491 ML20079F496 ML20079F500
References
ISSUANCES-OL-3, NUDOCS 8401180274
Download: ML20079F480 (5)

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00CNETED USNR UNITED STATES OF AMEPICA NUCLEAR REGULATORY COMMISSION gy JW 7 P2:52 Offbk Of 3:, ,

Before the Atomic Safety and Licensino Boah Eli*35 5 ,

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In the Matter of )

} Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY )

) (Emergency Planning)

(Shoreham Nuclear Power Station,)

Unit 1) )

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SUPPLEMENTAL DIRECT TESTIMONY OF DR. GEORGE JEFFERS AND ANTHONY R. ROSSI ON PEHALF OF THE MIDDLE COUNTRY CENTRAL SCHOOL DISTRICT AFD SUFFOLK COUNTY REGARDING CONTENTIONS 25.C AND 25.D O. Plecse state your names and positions.

A. I am Dr. George Jeffers, Superintendent of the Middle Country Central School District.

I am Anthony R. Rossi, Director of Transportation for the Middle Country Central School District.

O. What is the purpose of this testimony?

A. The purpose of this testimony is to supplement our testi-mony dated November 18, 1983 concerning Contentions 25.C and 25.D, in order to address changes contained in Revision 3 to the LILCO Plan with respect to proposals concerning schools.

8401180274 840116 PDR ADOCK 05000322 T PDR

O. Have you reviewed Revision 3 to the LILCO Plan?

, A. Yes, we have reviewed those portions of Pevision 3 that concern schools. These sections are pages II-10 to 10a, II-19 to 21, and IV-169 to 171 of Appendix A. Revision 3 proposes three general alternatives to provide for the safety of the students in the EPZ should there be an emergency at the Shoreham Nuclear Plant. In addition to early dismissal which we addressed in our November 18 testimony, the Plan now states that schools inside the EPZ may be advised to shelter or to relocate their students, depending on the recommendation made to the general public. Also, according to Revision 3, school districts such as ours, which have no school buildings in the EPZ but which do have students who live in the EPZ, would be advised to retain those students at their schools beyond the end of the school day, if any protective action is recommended for the general public.

O. Do these changes affect your opinion concerning the likely effect of role conflict on the workability of the LILCO propos-als?

A. No. Indeed, LILCO's new proposal would create a more se-vere role conflict problem for the Middle Country Central School District staff. Contrary to the situation with an early 2-

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dismissal, when staff is necessary at the schools until children board buses, and bus drivers drive their regular routes, under the new LILCO proposals, our staff would be ex-pected to remain with students for an indeterminate amount of time, keeping them from their responsibilities to their own families for a longer and indefinite period. And, any loss of personnel due to role conflict would be more detrimental to children's safety under LILCO's new proposals, because imple-menting those proposals would require even more school person-nel than would be reauired to implement an early dismissal.

Our district has approximately 1200 to 1300 students who reside within the 10 mile EPZ. They attend a total of at least 18 schools -- five in-district schools, and 13 additional schools outside the district. At the end of the school day, attempting to dismiss part of the school district (i.e., stu-dents who live outside the EPZ), while retaining students liv-ing within the 10 mile EPZ would lead to confusion and problems in accountability and safety.

Additional confusion would be caused by parents attempting to get their children and remove them from the premises. An increase in staff (over that required for a normal or early dismissal) may be required to process such a special partial l

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dismissal, and to secure the building to prevent parents, students and staff from attempting to use exits '(entrances) not sanctioned for that purpose. If additional staff were not available to guard all exits (entrances), people would be able to enter or leave at will, and the school staffs could not as-sure the accountability or safety of the children.

In addition, as noted in our November 18 testimony, we transport children to private and parochial schools both within and beyond the 10 mile EPZ and are concerned about the respon-sibility for caring for these students. Should any of these schools be advised to evacuate and relocate their students as proposed in Revision 3, they would not have the capability to transport them. That would be the responsibility of our dis-trict. Even if we were able to get to the schools and evacuate such children to a relocation center outside the EPZ, parents would be concerned as to where they would be able to pick up their children. In addition, presumably our district would also be responsible for supervision of those children until their parents arrived. This would be an additional obligation imposed upon our staff, not only would we have to provide bus drivers, but we would also have to send teachers or other staff members on the buses to the schools so they could then accompa-ny and supervise the children during the trip to, and once they

arrived at the relocaticn centers. If we were expected to pick up those students at schools and transport them to relocation -

cente s, bus drivers and other staff members would be faced with a role conflict. We believe that their concern for the safety of their own families as well as for their personal safety would keep laroe numbers of them from enterino the EPZ and therefore the LILCO proposals for evacuation and relocation could not be implemented.

The point is that LILCO's new proposals for protecting school children contained in Revision 3, make the problem of role conflict even more serious. Because our staff would be expected to remain at schools or otherwise away from their families for an even longer period of time than required for an early dismissal as discussed in our November 18 testimony, we believe an even larger number of our staff members would be likely to attend to their own families rather than perforr.. the jobs required to implement the LILCO proposals. And, as we have discussed, the new plans would recuire even more staff to implement them. Therefore, the effects of role conflict would make the new LILCO proposals even less workable that the prior LILCO proposal of early dismissal.

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